10-10-11: [35] Ecolaw Appeal: Press Appeals Panel: Judge Ralph Zulman

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11 October 2010 Judge Ralph Zulman Chair: Press Appeals Panel Press Council of SA 7 St. Davids's Park St Davids Place, Parktown, 2193 Tel: 011 484 3612/8 | Fax: 011 484 3619 E-mail: khanyim@ombudsman.org.za, johanr@ombudsman.org.za CC: DR. S. Cwele, Minister of State Security Email: bdube@nia.gov.za / tmhlamvu@intelligence.gov.za / ntmin@mweb.co.za Fax: (021) 461 4644 or (012) 367 0749 CC: Mr. Cecil Burgess, Chairperson of the Joint Standing Committee on Intelligence Email: cburgess@parliament.gov.za CC: All Concourt #23-10 Parties in The Citizen v Robert McBride.

Application to Appeal Denial of Hearing by Deputy Ombudsman Johan Retief: Radical Honesty White Refugee 35 Complaint Submissions to SA Press Council re: Concourt #23-10 proceedings. The issues dealt with in this Application to Appeal are as follows: Complaint to Press Ombudsman Record of Correspondence Appeal Issue #1: Deputy Ombudsman’s Representation Request for me to Sign a Waiver implied a Hearing where I could hear the Defence of the Publications. Denial of any Defendant’s argument, via Ombudsman’s dismissal, renders Complainants Waiver Null and Void. Appeal Issue #2: Either, the Deputy Ombudsman (a) did not impartially apply his mind with due diligence to my complaint, perhaps because I am not an important ‘elite’ person; or (b) endorses (i) the censorship of media corruption1: their censorship of non-violent dissent, and their role in Population Production of Poverty and Violence; for parasitic ‘If It Bleads, It Leads’ financial corporate benefits from political violence (para: 20-25 of my complaint), (ii) the censorship from the public of SA Media Editors discrimination and prejudice against White Refugees (para: 15-19). [A] Deputy Ombudsman’s Written Reasons for Dismissal: [B] Radical Honesty Argument Censored [C] Ombudsman Ignores other Issues raised in complaint: Lack of Fairness and Censorship by Omission: such as Censorship of Mr. McBride’s Arguments, etc. [D] Deputy Ombudsman’s Endorsement of Censorship of Information in the Public Interest [E] Sed quis custodiet ipsos custodies / But who shall guard the guardians? 1

Definition as per S.3 of Prevention and Combatting of Corrupt Activities Act, 2004


Complaint to Press Ombudsman Record of Correspondence: 

On Monday, October 04, 2010 3:33 AM, I submitted Complaint Submission to SA Press Council from Radical Honesty White Refugee, regarding 30 erroneous, unfair, biased newsarticles, which included their deliberate and malicious censorship of media corruption and other related information in the public interest.

On Monday, October 04, 2010 2:23 PM, I received Mr. Retief’s response in RE: Complaint Submission to SA Press Council from Radical Honesty White, wherein he requested me to provide him with a one page summary of my complaint (to submit to Publication Editors?), as well as to sign the waiver.

On Monday, October 04, 2010 9:02 PM, in RE: Complaint Submission to SA Press Council from Radical Honesty White Refugee, I requested Mr. Retief to clarify his request, by asking whether he (a) required a one page summary covering the entire complaint submitted against all 30 publications; or (b) a one page summary for each of the 30 publications.

On Tuesday, October 05, 2010 8:55 AM in, RE: Complaint Submission to SA Press Council from Radical Honesty White Refugee, Mr. Retief responded that he required one page summaries for both (a) and (b).

On Wednesday, October 06, 2010 3:04 PM, I submitted: Complaint 1 Page Summaries: [001-035] [001] [002] [003] [004] [005].

On Wednesday, October 06, 2010 3:07 PM, I submitted: SAPC Complaint: 1 Page Summaries [006] [007] [008] [009] [010]

On Wednesday, October 06, 2010 3:07 PM, I submitted: SAPC Complaint: 1 Page Summaries [011] [012] [013] [014] [015].

On Wednesday, October 06, 2010 3:07 PM, I submitted: SAPC Complaint: 1 Page Summaries [016] [017] [018] [019] [020].

On Wednesday, October 06, 2010 3:17 PM, I submitted: SAPC Complaint: 1 Page Summaries [021] [022] [023] [024] [025].

On Wednesday, October 06, 2010 3:17 PM, I submitted: SAPC Complaint: 1 Page Summaries [026] [027] [028] [029] [030].

On Wednesday, October 06, 2010 3:17 PM, I submitted: SAPC Complaint: 1 Page Summaries [031] [032] [033] [034] [035].

On Wednesday, October 06, 2010 3:28 PM, I submitted: Radical Honesty White Refugee: Waiver.

On Friday, October 08, 2010 12:42 PM, I submitted: [Update] Complaint Submission to SA Press Council from RHWR: Good Faith Withdrawal of CAS 823-08-2010., wherein I informed Mr. Retief of my good faith offer to provide him with an opportunity to make a full impartial enquiry into my complaints. I informed him that I had contacted SAPS Insp. Engel, to withdraw the charges of Conspiracy, Fraud, Bribery, Corruption & Obstruction of Justice against 20 SANEF editors, for their censorship of news by those whom they discriminate against, fraudulent representations to the SA public, and their own corruption, etc.

On Monday, October 11, 2010 12:47 PM, I received from Mr. Retief: Complaint, wherein he refuses to provide me with any hearing whatsoever, by dismissing my complaint, same as Ombudsman Thloloe did in 2008. One difference: Mr. Thloloe dismissed my complaint without ever requesting me to sign a waiver,


and he never informed me that I had the right to appeal his decision, how or when. My complaint was simply dismissed. As of filing this Application I have received no response whatsoever from any of the defendants to my allegations, let alone any meaningful response.

Appeal Issue #1: Deputy Ombudsman’s Representation Request for me to Sign a Waiver implied a Hearing where I could hear the Defence of the Publications. Denial of any Defendant’s argument, via Ombudsman’s dismissal, renders Complainant’s Waiver Null and Void. The SA Press Council website states: “We will not start the process until you assure us that you will not later take other legal steps against the publication – we don't want people who pretend to use the self-regulation system only to extract the defence of the publication and then try and use the information against it in the courts.” Does the SA Press Council require complainants to sign a waiver once their complaint has been approved for hearing, i.e. once they are guaranteed to hear the defence of the publication?; or without any guarantee that they may ever hear the defence of the publication, since their complaint can simply be dismissed without such a hearing? If the SA Press Council denies a complainant the right to a hearing, where they would have heard the defence of the publication; surely there is no requirement for them to sign a waiver? In terms of contract law, the signing of a waiver is an offer to make a concession, in return for a receipt of information (the argument of defendant publication). If the Press Council deny the complainant the right to the receipt of the information, they nullify the waiver/contract, which is consequently null and void.

Appeal Issue #2: Either, the Deputy Ombudsman (a) did not impartially apply his mind with due diligence to my complaint, perhaps because I am not an important ‘elite’ person; or (b) endorses (i) the censorship of media corruption2: their censorship of non-violent dissent, and their role in the Population Production of Poverty and Violence; for parasitic ‘If It Bleads, It Leads’ financial corporate benefits from political violence (para: 20-25 of my complaint), (ii) the censorship from the public of SA Media Editors discrimination and prejudice against White Refugees (para: 15-19). [A] Deputy Ombudsman’s Written Reasons for Dismissal: The Deputy Ombudsman’s ‘written reasons’ for dismissal of my complaint; after demanding I sign a waiver, and provide him with one page summaries of all my complaints (to provide copies to editors, for their response?) says: I have had a close look at your complaint and have also discussed it with Joe Thloloe, the Press Ombudsman. You complain that the omission of your argument as one of the amici curiae is an intentional, malicious campaign of censorship. However, the media summary issued by the Constitutional Court only mentions you as a friend of the court – it does not refer to any argument made by you (it does refer to the arguments of other friends of the court). Note: You do not complain that the news reports 2

Definition as per S.3 of Prevention and Combatting of Corrupt Activities Act, 2004


did not mention you as a friend of the court; your complaint is that your argument was ignored. This, I believe, partly explains the omission of your argument by the newspapers. Furthermore: Even if you notified the editors of your argument and issued a press release, they are under no obligation to publish the material. Your complaint is therefore dismissed.

[B] Radical Honesty Argument Censored The Deputy Ombudsman’s ‘close look’ refers to the omission of my argument, as if: (a) nothing in my Concourt argument – including information about media corruption and media prejudice and bias against white refugees -- might be a conflict of interest motivation for the media editors to censor; (b) nothing in my Concourt argument – not media censorship of their own corruption and bias, nor media’s censorship of the Population-Environment Connection; nor media’s censorship of the differences between cultures who practice sincere forgiveness (Radical Honesty) vs. cultures who practice fake, two-faced forgiveness (SA TRC) – is of any public interest (c) Effectively he endorses media editors to censor matters from the public interest, to cover up their corruption, their prejudice and bias, and their parasitic relationship to the population production of political violence; and he does not think the SA Public has any ‘public interest’ right to know about this media corruption. Put differently, the Deputy Ombudsman refers to my argument to the Concourt, as if the media censorship of media corruption arguments therein are totally irrelevant to his decision making; when in fact they are hugely relevant.

[B] Ombudsman’s Concourt Press Summary Reason: My complaint informs the Press Ombudsman that my application to the Concourt had expressly requested to submit written argument only, UNLESS any Justice had any question related to my argument. The 27 Sep 2010 Concourt order stated that I would not be required to submit oral argument, in paragraphs 10 and 26. The Concourts’ Press Summary was a Media Summary of the Pre-Hearing of Oral Argument, to be submitted on 30 September, hence it did not include my written argument, because I was not submitting an oral argument on that day. That does not mean my written argument is not one of the arguments before the Court in this matter.

[C] Ombudsman Ignores other Issues raised in complaint: Lack of Fairness and Censorship by Omission: such as Censorship of Mr. McBride’s Arguments, etc. Paragraph 30: [001] [002] and [003] only include the argument to be made to the Court by the Citizen, Mr. McBride’s argument’s to be made are totally ignored, as are all the arguments of the Amicus Curiaes.

Paragraph 32:


The following SAPA article, syndicated as [004] to [015] includes reference to Mr. McBride’s argument related to ‘contrition’, i.e. a factor involved in forgiveness; The Citizen’s argument related to a ‘reasonable reader’, but totally ignores the Radical Honesty SA Amicus Curiae which deals in great detail on issues of sincere vs. fake forgiveness, as well as how such factors affect the legal common law principle of the ‘reasonableness test’; i.e. the ‘reasonable reader’.

Paragaph 33: In the following SAPA article [016] – [017], SAPA include only the argument presented to the Constitutional Court by The Citizen, Mr. McBride’s argument and other Amicus Curiae arguments contradicting the Citizen are totally ignored. Nor are the skeletons of the media, in relation to their censorship of non-violent dissent, so as to create a pressure-cooker environment for violent terrorist acts for their ‘if It Bleads, it leads’ corporate profits, as contained in the Radical Honesty SA Amicus even hinted at.

Paragraph 34: In the following Court weighs validity of TRC past, SAPA/IOL article [018] – [025], SAPA totally censors the argument by Radical Honesty on the irregularities and illegalities, bias, censorship and omissions committed by the TRC, which contributed to SA’s state of fake, two-faced hypocrisy ‘reconciliation’. The article totally censors any mention whatsoever of the Radical Honesty SA Amicus Curiae argument before the Constitutional Court, regarding the validity or not, or selective invalidities of the TRC in the Radical Honesty SA Amicus.

Paragraph 35: The following articles in East Cape Radio, are amalgamations of ‘Skeletons’ [016] - [017] and ‘court weighs validity of TRC past’ [[018] – [025] SAPA articles, and the same aforementioned arguments of bias and censorship apply.

Paragraph 36: The following Citizen article [028] provides the details of the Citizen’s argument, that the TRC was allegedly about ‘truth-telling’ and promotion of national reconciliation. It totally censors the argument of Radical Honesty SA, which is directly to the contrary, that the TRC was a fraudulent PR publicity stunt, riddled with conflicts of interest, bias, omissions, censorship and that its focus – considering the TRC Commissioners response to Dr. Blanton’s allegations -- was not sincere reconciliation, but simply to label apartheid a ‘crime against humanity’ by irregular and biased practices. The article refers to all other Amicus Curiae’s and their arguments, but totally censors the Radical Honesty SA Argument before the Justices.

Paragraph 37: In the following Mail and Guardian article [029], Ms. Parker also provides details of the Citizen’s argument and Mr. McBrides argument. She also deals with The Citizens argument about the ‘reasonable reader’ and hence the reasonableness test, but totally censors the detailed argument related to sincere vs fake forgiveness and its relation to the reasonableness test, as made in the Radical Honesty SA Amicus. Similarly to SAPA and The Citizen, the Mail as far as the Mail and Guardian are concerned the Radical Honesty SA Amicus before the Constitutional Court in this matter does not exist.

Paragraph 38: In the following article by Eyewitness News, Mr. Stephen Grootes [030], his title alleges that Mr. McBride’s lawyers are playing with semantics; i.e. acting unethically. He totally censors any mention about how The Citizen’s lawyers, and SANEF’s lawyers are condoning the highly corrupt, conflict of interest and malicious censorship behaviour of their clients in this matter, as detailed in the Radical Honesty Amicus. His biased article appears to be motivated to encourage less than intelligent or impartial readers, or those who have not


yet forgiven Mr. McBride, to be opposed to impartially enquiring into Mr. McBride’s lawyers arguments with an open mind.

[D] Deputy Ombudsman’s Endorsement of Censorship of Information in the Public Interest The Deputy Ombudsman’s reasons state: Furthermore: Even if you notified the editors of your argument and issued a press release, they are under no obligation to publish the material.

He totally ignores my complaint of the media’s censorship of information in the public interest. According to the West Encyclopedia of American Law3, Public Interest is defined as: Anything affecting the rights, health, or finances of the public at large. Public interest is a common concern among citizens in the management and affairs of local, state, and national government. It does not mean mere curiosity but is a broad term that refers to the body politic and the public weal. A public utility is regulated in the public interest because private individuals rely on such a company for vital services.

In an Affidavit filed in the Witwatersrand High Court (05/16077): Imvume Management (Pty) Ltd v. M & G Media Limited, Ferial Haffejee, Stefaans Brummer, Sam Sole and Wisani Wa Ka Ngobeni, Guy Berger (in his capacity as Head of School of Journalism Studies at Rhodes University) and Robert Brand (in his capacity as Senior Lecturer in the School of Journalism and Media Studies at Rhodes University) state their expert witness opinions under oath on The concept of public interest generally in law and journalism, in paragraphs 77 – 84: 77. The concept of public interest, which plays a central role in journalism ethics and the law relating to defamation and privacy, is difficult to define. Our courts recognize public interest as a justification, or part-justification, for the publication of defamatory statements or invasions of privacy; however, even the courts have found the concept impossible to define or describe exhaustively. A distinction is often made between the public interest and that which merely titillates the interest of the public. The public interest implies that the public can derive some meaningful benefit from the information published. “It goes without saying,” says Burns (2001:167), “that the public has an interest in statements relating to the integrity or efficiency of public officers or figures”. 78. According to the authors of one of the standard texts on South African media law, “it is impossible and undesirable to give an exhaustive statement of the subjects which are of public interest” (Bell, Dewar & Hall 1990). Lord Denning’s words from London Artists Ltd. v Little, 1069 2 QB 375 391 B-C are often quoted in this context: “There is no definition in the books as to what is a matter of public interest. (…) I would not myself confine it within narrow limits. Whenever a matter is such as to affect people at large so that they may be legitimately interested in, or concerned at, what is going on; or what may happen to them and others; then it is a matter of public interest…” (Cited in Bell, Dewar & Hall 1990: 65) 79. Some examples of matters that may be in the public interest, according to Bell Dewar & Hall, are: 79.1. The public conduct of any man who holds, or seeks, a public office or 3

http://www.answers.com/topic/public-interest


position of public interest; 79.2. Political and state matters; 79.3. The management of public institutions. 80. According to Burns (2001: 193), courts may also consider whether the plaintiff is a public figure or involved in a newsworthy event; and “the motive, disposition or intention with which the defendant acts”. 81. The Press Ombudsman’s Code of Professional Practice states the following in connection with public interest: “The public interest is the only test that justifies departure from the highest standards of journalism and includes:  Detecting or exposing crime or serious misdemeanour;  Detecting or exposing serious anti-social conduct;  Protecting public health and safety;  Preventing the public from being misled by some statement or action of an  individual or organisation;  Detecting or exposing hypocrisy, falsehoods or double standards or behaviour on the part of public figures or institutions and in public institutions.” 82. The Code of Practice of the U.K. Press Complaints Commission has a similar description of public interest, but adds: “There is a public interest in freedom of expression itself. The Commission will therefore have regard to the extent to which material has, or is about to, become available to the public.” 83. Johan Retief (2002: 160) equates the public interest with the public’s “right to know”: “Sometimes the public has a legitimate need to know information that other people would like to keep private. The media’s task is in essence not to leave people alone.” 84. Ronning (2002: 71)) states that the public interest “has to do with the notion of social responsibility” and “with what is of essential social importance, of benefit to society, and of public concern for reasons of political and economic decision-making”..

In Media Regulation, public interest and the law, Mike Feintuck and Mike Varney write about how Public Interest includes an issue of plurality with a large range of perspectives. When the SA Media censor the perspective from a citizen whose cultural foundation is 100% honesty 100% transparency and a commitment to sincere forgiveness; in an interpretation of the TRC Act before the Constitutional Court; what does that say about the ‘Truth and Reconciliation’ media elite’s agenda about what information they consider in the ‘public interest’?: A particular point of interest here is the language used both in the Enterprise Act and Communications Act, where reference is made, respectively, to 'Public Interest Cases' and 'Media Public Interest Considerations'. Section 42(1) of the Enterprise Act allow reference by the Secretary of State to the OFT via an 'intervention notice' where a public interest consideration is relevant to a merger situation. Incorporated into section 58 of the Enterprise Act by section 375 of the Communications Act are really quite detailed specifications of what constitutes 'the public interest' in relation to mergers between newspapers, between broadcasters and in relation to mergers which cross the two sectors.


These provisions were added late in the Parliamentary process as something of a concession in the Lords and, as Ofcom notes, are 'often described as the plurality test'. Ofcom summarises the public interest criteria as follows: In the case of a newspaper merger, the public interest considerations, as deined by the Act, are: 1. The need for accurate presentation of news in newspapers; 2. the need for free expression of opinion in the newspapers involved in the merger; 3. the need for, to the extent that is reasonable and practicable, a sufficient plurality of views expressed in newspapers as a whole in each market for newspapers in the UK or part of the UK. In the case of a broadcasting merger or a cross-media merger, the public interest considerations defined by the Act are: 1. the need for there to be a sufficient plurality of persons with control of the media enterprises serving that audience in relation to every different audience in the UK or a particular area/locality of the UK; 2. the need for availability throughout the UK of a wide range of broadcasting which (taken as a whole) is both of high quality and calculated to appeal to a wide variety of tastes and interests; 3. the need for persons carrying on media enterprises and for those with control of such enterprises to have a genuine commitment to the attainment in relation to broadcasting of the standard objectives set out in section 319 of the Communications Act 2003 (for example, governing matters of accuracy, impartiality, harm, offence, fairness and privacy in broadcasting).

[E] Sed quis custodiet ipsos custodies / But who shall guard the guardians? In The Media and Paid News: Who Shall Guard the Guardians4, a Reuters Indian journalist writes: The media watches everyone but itself, commented an argumentative friend the other day. How many ‘sting operations’ has the media done on any of its own, say on the ‘Paid News’ controversy? I was at a loss. The morality of sting operations is a debatable topic but the larger point demanded a response. The media does investigative stories practically every week but does it deliberately avoid turning the gaze inwards?

One reason provided by one journalist for refusing to be critical of the lack of quality of her fellow journalists was: It meant alienating your own fellow professional colleagues.

In What some media don’t want you to think about5, Christi van der Westhuizen writes: I recently resigned as monthly columnist at Media24’s daily newspapers after one of my columns was censured. The offence that led to the censorship? As a proponent of the position that the media’s allergic reaction to self-criticism is to its own detriment, I had dared to do exactly that: employ critical examination of the media.

4

http://blogs.reuters.com/india/2009/12/24/the-media-and-paid-news-who-shall-guard-the-guardians/ http://www.thoughtleader.co.za/christivanderwesthuizen/2010/10/11/what-some-media-don%e2%80%99t-want-you-tothink-about/ 5


In A Mosquito Buzzing in the Dark followed up by The Hollow Men of Journalism, David Bullard writes about how former editor of the Sunday Times, Mondli Makhanya, now Chairman of SANEF, introduced forged documents into court proceedings, and how all other SA media editors censored this information clearly in the public interest. Imagine the chairman of any other public organization or political party introducing clearly forged documents into court proceedings, the media would be all over that court-room like vultures; but not when its their own corrupt chairman! Bullard concludes that SANEF editors appear to endorse and emulate the corruption of their chairman: Back on February 8th AVUSA introduced a new piece of evidence after the lunch recess. It purported to be the contract of Fred Khumalo dated July 2004. The purpose of this bit of late evidence was to demonstrate how different my contract was from his. The only problem was that this contract was on the notepaper of Avusa Media and that company didn’t start trading until 2008. And it wasn’t simply a case of an old document being accidentally photo copied onto a new piece of notepaper. The name AVUSA also appeared in the body of the document. So in court last Wednesday I respectfully accused Mondli Makhanya of having used the lunch recess to forge that document. …. So here’s the situation. The HR department at AVUSA provided a document dated July 2004 to Mondli Makhanya which he claims is genuine. Indeed he has appeared before a commissioner of oaths and signed a sworn affidavit as to its authenticity. The fact that two of the directors on that letterhead were only appointed to the board after 2004 doesn’t seem to have bothered Makhanya; or the rather slipshod but psychic HR department. How clever of them to have already printed company notepaper with the names of directors who would only be appointed a few years later. ……. Not surprisingly the rest of the media have refused to report on this. Back in February award winning journalist Mandy Weiner from Talk Radio 702 researched the story after a meeting with me. She saw the “questionable” contract, interviewed an independent witness (who I have never met) who was prepared to testify that he had been told to back date court documents by Makhanya and tried to phone Makhanya but he didn’t answer his cellphone. The story was hot… “Newspaper editor introduces forged evidence in court” and was due to go live on the 6pm Eyewitness news. But Makhanya had already phoned his mate Katy Katapodis who spiked the story. The code of omerta between certain journalists is strong. ……. What worries me most about this case is that two senior journalists are quite prepared to lie to advance their personal interests. Both have opened themselves to future criminal prosecution by signing sworn affidavits that a document that could not possibly have existed is genuine. Clearly they are both of the opinion that they are above the law and are untouchable. But at a time when the print media is pleading to be allowed to self regulate itself this provides as strong an argument as I can think of for that request to be denied. And how on earth can a man like Makhanya possibly be allowed to represent journalist’s interests as the Chairman of the South African National Editor’s Forum? Unless, of course, SANEF members see nothing wrong in this and behave the same way themselves. ….. It's now been four weeks since the column “A mosquito buzzing in the dark” was published on NewsTime and the silence has been deafening. As many of you commented at the time, here was a column that was surely red rag to a bull. Unless, of course, the content was true, in the public interest and could be proven in a court of law. I think, after four weeks, it's fair to assume that the allegations in that column were so horribly accurate that the parties concerned didn't even dare to squeak in protest.

The media profess to be the guardians and watchdogs of the government; hence surely they should be held at the very least to the exact same standards of ‘information in the public interest’ to the Government. They cannot accuse the Government of practicing censorship of information clearly in the public interest, when they do exactly the same thing, and worse.


In fact this matter was raised with the Deputy Press Ombudsman, in paragraphs 42 – 44: Is SANEF Media Corruption Greater than ANC Corruption? Nobody doubts that a significant number of ANC officials are corrupt. Perhaps a Milgramesque6 92 % of ANC officials lack the skills and capabilities to either (a) resist the temptation from participating in the dominant corrupt paradigm, and/or (b) are able to resist actively participating in the dominant corrupt paradigm, but unwilling to risk exposing their fellow colleagues corruption. However, there have been, and continue to be ANC members who do have the courage to both resist actively participating in the corruption gravy train, and to cross the line, by exposing their fellow ANC colleagues corruption. While SANEF Editors, as partners of the World Association of Newspapers, no doubt allegedly officially support the Declaration of Table Mountain to Abolish "Insult Laws" in Africa and Set a Free Press Higher on the Agenda; when SANEF editors were contacted to support the Freedom of Expression for a member of the Radical Honesty culture’s freedom of expression from legal and political persecution and prosecution for allegedly privately insulting a politician; none of SANEF editors had the courage to demonstrate their constitutional commitment to the Declaration of Table Mountain principles. Certainly in this Concourt matter, as demonstrated in paragraph 28 of the Complaint to the SAPS (Annex E), not one SA media editor or media professor contacted was remotely interested in making an impartial enquiry, or objecting about their fellow media editors corruption. Consequently in this matter, not one SA media elite possessed the skills and capabilities of the 8% of ANC members, who have the courage to cross the line, by exposing their fellow media elite’s corruption in this matter. Is this an isolated and exceptional case or is this kind of blind obedience to censorship and silence about media corruption fully entrenched in SA’s corporate media elite? It appears plausible, considering the allegations made in Mr. David Bullard’s columns, among others, The Hollow Men of Journalism 7, and A mosquito buzzing in the dark *8, that indeed there is very little skills and capabilities on the part of the SANEF corporate media elite to expose their own peers corruption. Consequently, when it comes to resisting peer corruption, at least in this matter, and Mr. David Bullard’s legal matters, 100% of SA media editors are as ideologically obedient to their code of silence about fellow media editors corruption, and unquestioning of such obedience to their silence and censorship of media corruption, as Adolf Eichmann was to Nazism.

Respectfully Submitted,

Lara Johnstone Member Radical Honesty Culture and Religion Annexures: A. Complaint to SA Press Council: Radical Honesty White Refugee Complaint to SA Press Council. B. Dismissal of Complaint Email from Deputy Ombudsman, Complaint.

6 See Annex C: Radical Honesty SA Amicus Curiae: [II] Truth and Forgiveness Social Contract Principles: (B). Stanley Milgram Studies on Obedience: Legal, Socio-Political Implications, para.29; (C). Common Law Reasonableness Test: Skills and Competencies, para.30; and (D). Rule of Law and Forgiveness: Individuality, Independent and Integrity, para.31-33 7 http://www.newstime.co.za/rs_articles_contributors.asp?conid=9&recid=2357 8 http://www.newstime.co.za/column/DavidBullard/A_mosquito_buzzing_in_the_dark*/9/2200/


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